POL00070480 - Telephone Attendance Note of Stephen Dilley with Tom Beezer, Mandy Talbot re next steps Royal Mail Group PLC Sub Postmaster Litigation - Matter: Mr Lee Castleton

Evidence on official site

POL00070480
POL00070480

Telephone attendance

Client: Royal Mail Group PLC Sub Postmaster Litigation

Matter: Mr Lee Castleton Matter no: 348035.134
Attending:

Name: Stephen Dilley Location: N/A Date: 23 November 2005
Start time: Units:

I had a telephone conference with Tom Beezer (BP) and Mandy Talbot (Post Office). We agreed the
following next steps:

1. I will continue to go through all of the receipts from the Post Office to make a precise list of what
we have received. Once I have completed that list I will ask Mr Jones, Mrs Oglesby and Lesley
Joyce whether that list is complete or whether there ought to be other documents. If there are
any other documents I will pursue every avenue I can to try and get them back but Lesley Joyce
might be the right person.

2. Iwill telephone David Halbert of the Post Office to ask him what will be the cost and ease of
retrieving data about Fujitsu and other cases the Post Office may have.

3. Iwill prepare witness statements for John Jones, Helen Hollingsworth and Cath Oglesby. Once
these are in relatively good draft form, I will send them to Mandy & Tom for approval.

4. Iwill ask Helen Hollingsworth whether the auditors did a cash account themselves, if I cannot
find one amongst the papers I have.

5. Iwill get the post office documents copied and sent to Cath Oglesby, Helen Hollingsworth and Mr
Jones so that this will help build their witness statements.

6. Tom recommended Richard Morgan or Michael Gibbon of Maitland Chambers to do this job. He
said that they were both good on their feet, technically minded and good advoctas. Mandy
Talbot asked Tom to check whether any of the two of them had got technology experience as
she thinks this could be useful if this case. Previously she has used Devereaux Chambers, but
that is where the other side deny the terms of the employment contract. This is not the case in
this instance.

7. In any event I will email to Mandy Talbot those Counsel from Deveraux who we are told this
morning are available to attend hearing on 6 December. Tom will buzz to Mandy Counsel from
Maitland Chambers and their profiles.

8. The question for Mandy to ask at the meeting on Friday is to ask whether the rebooting of the
system will change the cash accounts.

9. Mandy asked me for a copy of the expert’s reports that she stated that she hadn’t seen. I

reminded her that I had sent them to her a few weeks ago, and further copies were enclosed
with the bundle that I had sent to her yesterday, but I could always send them by PDF.

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Tom made it clear that we were to get Counsel involved at an early stage as BP were picking up the tab
for rectifying the default judgment and he wanted to go for a sledgehammer approach. Mandy agreed.
Mandy would prepare an internal report for her colleague at the Post Office.

vv minutes.

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